Summary
California Supreme Court case involving a habitual felon’s claim that his conviction of driving without a license should be overturned because the judge failed to instruct him that admitting his guilt to that offense would waive some of his constitutional trial rights. Randolph Farwell was convicted of vehicular manslaughter after his reckless driving resulted in his car hitting a tree at high speed, killing a female passenger. At the time of the crash, Farwell’s license had been suspended after an earlier reckless driving arrest. Farwell also had a previous conviction for burglary. At trial, Farwell and his attorney agreed to admit guilt on the suspended license charge to prevent jurors from hearing the details of the earlier driving arrest. On appeal, Farwell argued that the law required his conviction to be overturned because the judge did not instruct him on the consequences of his admission of guilt. CJLF joined the case to oppose Farwell’s claim, arguing that the law actually allows a review of the entire trial court record to determine if he knowingly and intelligently waived his trial rights when he admitted guilt on the driving without a license charge. The applicable test is whether, under the totality of the circumstances, a defendant knowingly and voluntarily waived certain trial rights. This test is applicable to all cases in which a trial court fails, either partially or completely, to advise a defendant of these rights. A reviewing court can look at the entire record, not just the record at the time of the plea or stipulation, to determine if a defendant’s waiver was voluntarily and intelligently given. The California Supreme Court agreed with our position.
